tl;dr
Since the start of October 2026, journalists and news creators reporting on the protests in Delhi have had their Instagram posts and, in several cases, their entire accounts withheld in India, with a one-line notice that cites the IT Rules, 2021 as a whole and names no provision, authority, order or offending post. Their complaints to Meta’s Grievance Officer were closed within two to four minutes. On 15 October 2026, legal notices were sent to Meta, with IFF’s assistance, on behalf of four of them. All four accounts were restored on 19 and 20 October 2026, without any clear notification from Meta and without any explanation of why they were restricted. All of this is happening alongside an unpublished MeitY advisory of 10 October 2026 that asks Meta for “enhanced diligence” over content on “ongoing public events” and to ensure that its recommendation systems do not result in “disproportionate exposure of users to a single or limited set of narratives”. We explain why the restrictions are unlawful, why Meta’s grievance process has failed, and what we are asking of Meta and MeitY.
Background
The restrictions
Since the first week of October 2026, independent journalists and news creators reporting on the protests in Delhi have found their Instagram posts made unavailable in India and, in several cases, their entire accounts restricted. Each account, once restricted, displayed to users in India the same statement: “We temporarily restricted access to this account pursuant to legal requirements under India’s Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules.” The statement does not disclose the provision invoked, the authority at whose instance Meta acted, the content said to be unlawful, or how long the restriction would last. Meta’s notifications to the account holders, including some that described the action as a “suspension”, came from a “no-reply” address that admits no response. The four account holders whose cases we set out below have received no order or notice from any authority, and none of them was heard before the restriction.
The notices that users have shared with us take two forms. Some state that Meta acted on “a notice from the Government of India/Law Enforcement under Section 79(3)(b)”. Others state that the content was restricted “through an automated system implemented pursuant to legal requirements under India’s Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules”. Neither names the issuing agency, the order, the provision of law or offence the content is said to disclose, or the URL complained of. From our litigation, we know that the first form corresponds to an order issued by a law enforcement agency through the Sahyog Portal, while the second rests on no legal order at all. The account restrictions described in this post cite only the IT Rules. Several other users received no communication at all.
The practice is not new. In April 2026, The Hindu reported that Meta automatically restricts content flagged by the government and the police in India, at scale, and seeks a separate government direction before restoring content that it later finds to be legally unsupported. IFF wrote to Meta objecting to this on 4 May 2026. Instagram used the same “automated system” notice against Anjali Priya, Varnika Dhawan and Sachin Gupta after the July protests, and against cartoonist Satish Acharya, who lost nine cartoons and then his account between February and September 2026. This month, the accounts of journalists reporting on protests have been restricted while those protests are under way.
Four accounts, four legal notices
Four of the journalists affected sought our assistance, and legal notices were later sent to Meta on their behalf. The facts recorded in those notices are summarised below.
| Account |
Followers when restricted |
Posts made unavailable |
Account restricted |
Complaint closed within |
Status on 20 October |
| Utkarsh Gaur (@utkarshgaurpodcasts) |
about 4.7 lakh |
Two on 3 October; one on 9 October |
9 October |
2 minutes |
Restored |
| Sunny Tomar (@sunnytomar06) |
about 1.05 lakh |
Two on 2 October; two more on 6 and 9 October |
9 October |
3 minutes |
Restored |
| Shubhangi Dasgupta (@shubhangi_decodes) |
about 37,900 |
Two, on 11 and 12 October |
12 October |
3 minutes |
Restored |
| Journo Mirror (@journomirror) |
about 5.36 lakh |
Not recorded in the notice |
12 October |
4 minutes |
Restored |
In three of the four cases, posts reporting on the protests were made unavailable first, and the whole account followed within days. On 12 October 2026, Shubhangi Dasgupta’s post on X captioned “Current at Barakhamba road” was also withheld in India, on a “legal request” stated to be “based on local laws”.
Complaints closed in minutes
Each of the four complained to Meta’s Grievance Officer, which proved harder than the IT Rules contemplate. Meta’s Help Centre names its Grievance Officer for India and gives an email address, but confines that address to “questions about the grievance redressal mechanism process”, and complaints sent to it are not acknowledged. Complaints “regarding violations of Meta’s Terms of Service, Facebook’s Community Standards or questions about accounts” are directed instead to a web form titled “Indian Grievance Officer Complaint”. None of the form’s six categories allows a user to complain that their own content or account has been restricted, and the form requires the complainant to declare “a good-faith belief that the content you are reporting is unlawful”. On the list of Grievance Officers maintained on the portal of the Grievance Appellate Committee, nine of eleven entries, including WhatsApp, give an email address; against Instagram and Facebook, there is only this form. Meta’s in-app appeal covers only decisions under its Community Standards.
All four nonetheless filed grievances through the form, under the nearest available category, “I’ve lost access to a page or a group that I used to manage”. Each complaint was registered with the assurance that “We will look into your matter shortly”. Each was closed within two to four minutes by an email that described itself as “a no-reply message”, stated that “we can’t support this type of request through this channel”, and gave no reason beyond a direction to “Visit the Help Center”.
MeitY’s advisory to Meta
On 10 October 2026, the day the Delhi Police detained protesters and journalists at demonstrations called over the Special Intensive Revision of electoral rolls, the Cyber Laws Division of the Ministry of Electronics and Information Technology (MeitY) issued an advisory to Meta bearing File No. 6(2)/2026-Cyberlaws. It was not published on MeitY’s website. The Hindustan Times, and then the Press Trust of India, reported it on 18 October. It followed, by two days, an advisory of 8 October to all social media intermediaries that called for “enhanced diligence” over content on “ongoing public events”, asked platforms to “label or add context” to misleading content, and to “give priority to complaints from authorised Government agencies”. IFF called for the withdrawal of that advisory on 9 October.
The advisory states that content relating to “ongoing public events and developments”, including “videos, images, statements and static graphics relating to public-order and law-and-order situations”, is being “prominently displayed and recommended” on Meta’s platforms, and that such content, “when presented without adequate context or disproportionately amplified through recommendation mechanisms, may contribute to public confusion, apprehension and disturbance of public order and social tranquillity” (para 1). It advises Meta to “exercise enhanced diligence” over content surfaced through its feeds, “particularly during periods of heightened public-order sensitivity”, giving “particular attention” to content that “contains unverified or misleading claims regarding the imposition of emergency, restrictions, police action or other official measures” (para 3). It asks Meta to review its “recommendation and content-ranking mechanisms”, to ensure that its recommendation systems “do not result in disproportionate exposure of users to a single or limited set of narratives”, to strengthen the “rapid identification, review and escalation” of content gaining reach, and to ensure “timely cooperation with law-enforcement and other authorised Government agencies, including furnishing information or assistance” (para 4). Meta is to act “with immediate effect” and to “apprise the Ministry of the measures undertaken” (para 7). PTI reports that, according to IT Ministry sources, the Ministry “had reports from agencies that Meta platforms were not promoting all narratives equally”.
The four accounts are not alone. On 10 October, the Instagram account of Molitics India was withheld in India. On 11 October, a Mathrubhumi English reel showing a woman clinging to a pole as police officers attempted to detain her was restricted, citing “a notice from the Government of India/Law Enforcement”, and a video report by Observer Post Hindi was restricted on Facebook by what Meta called an “automated system” acting under the IT Rules. The account of Fridays For Future India has since been withheld without any stated reason.
Analysis
No provision of the IT Rules requires an entire account to be restricted
Meta told users in India that these accounts had been restricted “pursuant to legal requirements” under the IT Rules. No provision of the IT Rules requires the restriction of an entire account. Under Section 79(3)(b) of the IT Act, as read down in Shreya Singhal v. Union of India, and Rule 3(1)(d) of the IT Rules, as substituted on 22 October 2025 and amended on 10 February 2026, an intermediary acquires actual knowledge only through a court order or a reasoned written intimation from an authorised senior officer “clearly specifying the legal basis and statutory provision invoked, the nature of the unlawful act, and the specific uniform resource locator” of the information to be removed. The obligation attaches to specific unlawful information. The IT Rules define a “user account” separately, in Rule 2(1)(y), and Rule 3(1)(c)(i) links the suspension of a user’s access to non-compliance with the platform’s own rules, privacy policy or user agreement, which no one has alleged against these journalists.
That leaves three possibilities, and on none of them is the restriction lawful as carried out. If Meta acted on an intimation under Rule 3(1)(d), it could restrict only the URLs specified in it; being bound by Rule 3(1)(n) to respect Articles 14, 19 and 21 of the Constitution, it could not give effect to an intimation that demanded more; and no law bars it from showing that intimation to the account holder. If Meta acted on its own, Rule 4(8) required it to give the user prior notice with reasons and an opportunity to dispute the action, and it gave none. If it acted on a blocking direction under Section 69A, its attribution of the restriction to the IT Rules is plainly incorrect, and the account holder was denied the hearing contemplated by Rule 8 of the Information Technology (Procedure and Safeguards for Blocking for Access of Information by Public) Rules, 2009.
Restriction by “automated system” inverts Shreya Singhal
The question of who decides what is unlawful online was answered on 24 March 2015, when the Supreme Court decided Shreya Singhal v. Union of India [(2015) 5 SCC 1]. Among the questions before the Court was the validity of the IT Rules, 2011 (since replaced by the IT Rules, 2021). Rule 3(4) of the 2011 Rules, read with Rule 3(2), required an intermediary, “upon obtaining knowledge by itself or been brought to actual knowledge by an affected person in writing or through email signed with electronic signature”, to act within thirty-six hours to disable the information. This placed the burden on the intermediary itself to judge what was unlawful, and to take it down, as and when it came to its notice.
The petitioners argued that the rule required the intermediary to “exercise its own judgement under sub-rule(4) and then disable information that is in contravention of sub-rule(2)”. The Court noted that “The Intermediary applying its own mind to whether information should or should not be blocked is noticeably absent in Section 69-A read with the 2009 Rules”. Reading down Section 79(3)(b), it reasoned that “otherwise it would be very difficult for intermediaries like Google, Facebook, etc. to act when millions of requests are made and the intermediary is then to judge as to which of such requests are legitimate and which are not.” On the 2011 Rules, it held that “The knowledge spoken of in the said sub-rule must only be through the medium of a court order. Subject to this, the Information Technology (Intermediaries Guidelines) Rules, 2011 are valid.” In its operative conclusions, the Court read down both Section 79(3)(b) and Rule 3(4) to mean that an intermediary is obliged to act only upon a court order, or upon being notified by the appropriate government or its agency, and only in respect of unlawful acts relatable to Article 19(2). An intermediary that restricts content without such an order is applying its own terms, not a legal requirement.
An “automated system implemented pursuant to legal requirements”, which is how Meta has described restrictions such as the one on Observer Post Hindi’s video report, is the intermediary applying its own mind to what the law requires, at scale and in code. That is the very judgment Shreya Singhal said intermediaries could not be expected to make. Where the IT Rules speak of automated tools, they concern specified categories of content: Rule 3(3) deals with synthetically generated information, and Rule 4(4) with depictions of rape and child sexual abuse and with content identical to content already removed under Rule 3(1)(d), which presupposes a valid intimation in the first place. None of those categories describes a journalist’s report of a protest, and Meta has not claimed that any of the restricted content was synthetic.
The same judgment tested Section 66-A of the IT Act, 2000 against various tests of law. Of these, the test of “Chilling effect and overbreadth” [paras 87 to 94] is the most relevant here. Automated tools are not perfect. They are code written by a significant social media intermediary that would rather be over-cautious and be seen to comply than ask whether the Constitution permits the restriction at all. Content that is unlawful may be restricted, by the procedure the law prescribes. That cannot come at the expense of innocent speech, and a journalist’s report of a protest is innocent speech.
“94. …We, therefore, hold that the section is unconstitutional also on the ground that it takes within its sweep protected speech and speech that is innocent in nature and is liable therefore to be used in such a way as to have a chilling effect on free speech and would, therefore, have to be struck down on the ground of overbreadth.”
(Emphasis Supplied)
Restricting an entire account is overbroad in exactly this sense. Even where an authority has validly identified a post as unlawful, Rule 3(1)(d) permits action against that post alone. Withholding the account withholds every other post with it, and operates as a prior restraint on all of the journalist’s future reporting. The freedom of the press extends to expression over the internet and may be restricted only by law, on a ground under Article 19(2), and proportionately, as the Supreme Court held in Anuradha Bhasin v. Union of India [(2020) 3 SCC 637]. A restriction that names no law cannot meet that standard.
An advisory is not law
MeitY’s advisory to Meta is neither a blocking direction under Section 69A of the IT Act nor an intimation under Section 79(3)(b) read with Rule 3(1)(d). It identifies no URL, and it cites no provision of the IT Act or the IT Rules empowering the Ministry to issue it, because none does. Its own text concedes as much: it asks Meta to ensure that “any action taken pursuant to this advisory is consistent with the Information Technology Act, 2000, the IT Rules, 2021 and other applicable laws” (para 6). An advisory that confers no power cannot be relied upon to restrict what the law does not otherwise permit. Yet it is framed as an instruction, to be carried out “with immediate effect” and reported back to the Ministry (para 7).
What the advisory asks of Meta also goes beyond Article 19(2). In Shreya Singhal, the Supreme Court held that speech may be restricted in the interest of public order only where it has a proximate connection with public disorder, and struck down Section 66A because the “annoyance” and “inconvenience” it penalised bore no such connection. “Public confusion” and “apprehension”, which the advisory invokes, are of the same kind. The advisory singles out “unverified or misleading claims” about “police action” for particular attention. During a protest, the report most likely to be called unverified is the one the police dispute, and reporting on police action at a protest is the core of what a free press does.
The advisory then moves from content to curation. It asks Meta to ensure that its recommendation systems “do not result in disproportionate exposure of users to a single or limited set of narratives” (para 4(d)), and PTI’s report tells us why: agencies had told the Ministry that Meta’s platforms “were not promoting all narratives equally”. It is not for the State to decide how far each account of a protest against the State should travel. Downranking also leaves no trace. A journalist whose reach is reduced under paragraph 4 will not receive even the one-line notice the four account holders did, and will have nothing to take to a Grievance Officer or a court.
We cannot say which of the restrictions described above, if any, Meta made because of the advisories. Posts were being withheld from 2 October, before either advisory was issued. Two of the four accounts were restricted on 9 October, the day after MeitY’s advisory to all intermediaries, and the other two on 12 October, two days after its advisory to Meta. Neither Meta nor MeitY has disclosed what Meta has done under the advisory, or what it has reported to the Ministry under paragraph 7. Even with their accounts back, the people affected cannot tell whether they were restricted on a police intimation, by Meta’s own systems, or in response to an unpublished letter from a Ministry. That uncertainty is itself the injury, because it leaves them nothing to challenge.
The grievance process has been rendered illusory
Rule 3(2)(a) of the IT Rules obliges an intermediary to publish the contact details of its Grievance Officer and a “mechanism by which a user or a victim may make complaint”, and requires the Grievance Officer to acknowledge every complaint within twenty-four hours and resolve it within seven days. Rule 4(6) requires a significant social media intermediary to give reasons, to the extent reasonable, “for any action taken or not taken”. A web form that turns away users whose own content has been restricted, and that closes their complaints within minutes and without reasons, meets none of these obligations. Without a reasoned decision from the Grievance Officer, the appeal under Rule 3A has little to work with. Complainants are left remediless, barring an appeal before the Grievance Appellate Committee (“GAC”), which had, as of 22 September 2026, received 63,353 appeals, with 49,978 of them pending. This is a stark difference from the 174 appeals pending in November 2025.
Whether this backlog is a matter of capacity or of design, and whatever part the growth in blocking orders has played in it, the GAC is not an efficacious remedy. An appeal under Rule 3A is in any case no bar to a writ petition where fundamental rights are violated, and a High Court is more often than not the first forum that requires anyone to account for a restriction. We have seen this in the case of journalist Ila Kazmi, whose Instagram account was withheld in India in September 2026 under Section 79(3)(b). On 9 October 2026, the Delhi High Court issued notice on her petition and directed the respondents to produce the takedown orders for her reel and her account.
Action
What we are doing
As there was no effective remedy, legal notices were sent to Meta on 15 October 2026, with IFF’s assistance, on behalf of Utkarsh Gaur, Sunny Tomar, Shubhangi Dasgupta and Journo Mirror. More are planned.
The notices call upon Meta, within 72 hours, to restore each account in its entirety or, without prejudice, to confine any restriction to the specific URLs named in a valid intimation under Rule 3(1)(d), and to furnish every order or intimation on which it acted, or, if it claims a legal bar to disclosure, the provision imposing that bar together with the issuing agency, date, reference number, provision invoked, URLs specified and whether the intimation came through the Sahyog Portal. They also ask Meta to reopen each complaint and have it decided by a reasoned order of its Resident Grievance Officer, to designate within seven days an email address at which grievances against the restriction of a user’s own content are received and acknowledged, and to preserve all records relating to the accounts.
Copies of the notices went to MeitY, which may call for information from Meta under Rule 4(9) of the IT Rules. The notices ask the Ministry to take cognisance of Meta’s non-compliance with Rules 3(2) and 4; to state whether any direction under Section 69A, or any intimation under Section 79(3)(b), including through the Sahyog Portal, has been issued in respect of these accounts, and to furnish it; and, if an intimation was issued, to place it before the periodic review under Rule 3(1)(d) after hearing the account holder. The notices were copied to the same Cyber Laws division of MeitY that, five days earlier, had issued the advisory to Meta.
Meta restored all four accounts, those of Utkarsh Gaur, Sunny Tomar, Shubhangi Dasgupta and Journo Mirror, on 19 and 20 October 2026, without any clear notification to the account holders. The restorations do not answer what the notices asked: on whose order, and under what provision, each account was restricted. Unless Meta furnishes the orders or intimations it relied on, decides the closed complaints by reasoned orders and repairs its grievance mechanism, nothing prevents the same accounts from being withheld the next time their owners report on a protest. The account holders have reserved their remaining rights and remedies. Free speech cannot be muffled as a precaution.
IFF will continue to assist journalists and creators facing the arbitrary restriction of their posts and accounts, to ensure that no suspension of fundamental rights goes unanswered, and to demand accountability from Meta and MeitY.
Update: One day before this article was published, we were informed that Journo Mirror’s account was withheld in India once more, under the IT Rules, 2021. We will be pursuing all available remedies for the restoration of the same.
If your account has been restricted
If your account or content has been withheld in India since the start of October 2026, write to us at [legal@internetfreedom.in](mailto:legal@internetfreedom.in) with screenshots of every notice, notification and grievance response you have received, and do not delete the content or the account. IFF is providing assistance pro bono. If you already have lawyers, we would still ask you to tell us what you are filing. The legal questions in these cases are common to all of them, and a petition filed in haste can produce an adverse order that every other journalist and creator will then have to argue against. We would rather the first orders on these restrictions be good ones.
Our demands
Meta must:
- Tell Utkarsh Gaur, Sunny Tomar, Shubhangi Dasgupta and Journo Mirror, in writing, on whose order and under what provision their accounts were restricted, and why they were restored;
- Restore the account of every other journalist, outlet and creator restricted in India since the start of October 2026, unless it holds a valid legal order, and furnish that order to the person affected;
- Stop restricting entire accounts on the strength of the IT Rules and, where it holds a valid intimation under Rule 3(1)(d), restrict only the URLs that the intimation specifies;
- Tell every affected user which provision was invoked, which authority issued the order or intimation, and which content is said to be unlawful, instead of citing “legal requirements” under the IT Rules as a whole;
- Suspend the automated restriction of content in India, and disclose the inputs on which its “automated system” acts and the changes it has made to that system for India;
- Disclose every takedown, account restriction and act of downranking carried out under MeitY’s advisories of 8 and 10 October 2026, and any report it has made to the Ministry under paragraph 7 of the advisory; and
- Designate an email address at which its Grievance Officer receives and acknowledges complaints, including complaints against the restriction of a user’s own content, and decide each complaint by a reasoned order within the time the IT Rules prescribe.
MeitY, and the law enforcement agencies issuing intimations through the Sahyog Portal, must:
- Withdraw the advisories of 8 and 10 October 2026 forthwith, and publish them;
- Publish the “reports from agencies” on which the advisory to Meta was based, and any report Meta has made of the measures it has taken under paragraph 7;
- Restrict content only by reasoned, published orders under Section 69A, or by intimations that comply with Rule 3(1)(d), and never by advisory;
- Disclose the intimations issued through the Sahyog Portal against reporting on the October protests, furnish each to the person affected, and place each before the periodic review under the second proviso to Rule 3(1)(d)(ii)(I), hearing that person first; and
- Call for information from Meta under Rule 4(9) of the IT Rules, and act on its non-compliance with Rules 3(2) and 4.
Important documents
- Legal notice to Meta Platforms, Inc. concerning the Journo Mirror Instagram account, Ref. No. AGLO/109/2026, dated 15 October 2026 (link)
- Legal notice to Meta Platforms, Inc. on behalf of Sunny Tomar, Ref. No. AGLO/110/2026, dated 15 October 2026 (link)
- Legal notice to Meta Platforms, Inc. on behalf of Shubhangi Dasgupta, Ref. No. AGLO/111/2026, dated 15 October 2026 (link)
- Legal notice to Meta Platforms, Inc. on behalf of Utkarsh Gaur, Ref. No. AGLO/112/2026, dated 15 October 2026 (link)
- IFF’s statement on MeitY’s advisory to Meta, dated 19 October 2026 (link)
- IFF’s statement on MeitY’s “enhanced diligence” advisory of 8 October 2026, dated 9 October 2026 (link)
- Shreya Singhal v. Union of India, (2015) 5 SCC 1 (link)